[REVISION HISTORY]
Greek Council of State tax rulings
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What changed
2026-11-01 16:03 UTC → 2026-11-03 05:03 UTC ·
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removed
The Greek Council of State has issued several rulings clarifying tax administration, property acquisition, and audit timelines. Regarding real estate, Decision 2086/2025 specifies that if a property is purchased below its official objective value, the buyer must justify the actual amount paid to satisfy acquisition criteria, provided the transaction is provable. However, the transfer tax remains calculated based on the higher of the two values. On the matter of audit timelines, the court has distinguished between general audits and tax evasion cases. While the standard statute of limitations is five years, the Council of State ruled that this may be extended to ten years if new, supplementary evidence emerges that could not have been objectively identified during the initial period. This was illustrated in a case involving a company using fictitious invoices, where the discovery of the violation via In a subsequent audit report justified landmark decision, 1246/2026, the extension. Conversely, regarding tax evasion penalties, Decision 1246/2026 court declared the 20-year and 10-year statutes of limitations unconstitutional. The court found the 20-year provision violated the principle of proportionality and that the 10-year transitional provision violated Article 78 of the Constitution due to its retroactive application to the 2013 tax year. This ruling forces reinstates the standard five-year period as the primary timeframe for the state to issue assessments or fines, unless specific legal circumstances exist to suspend or interrupt the period. This decision significantly impacts cases from the 2012–2017 period, providing legal grounds for taxpayers to challenge assessments maintained via extended timelines. Consequently, the Independent Authority for Public Revenue (AADE) must re-examine files to operate within a stricter five-year window distinguish between expired cases and those with valid legal reasons for many cases, particularly affecting the 2012–2017 tax years. extensions. While the decision does not trigger an automatic horizontal deletion a blanket cancellation of all debts from the 2012–2017 period, debt, it allows for the cancellation annulment of assessments made issued after legal time limits expired. Consequently, the AADE is accelerating audits to finalize assessments before a December 31, 2026, deadline, prioritizing income tax and VAT files. legal five-year window closed.
Versions
- 2026-11-03 05:03 UTC Greek Council of State tax rulings
- 2026-11-01 16:03 UTC Greek Council of State tax rulings
- 2026-10-30 08:54 UTC Greek Council of State tax rulings
- 2026-10-08 03:14 UTC Greek Council of State tax rulings
- 2026-10-04 07:23 UTC Greek Council of State tax rulings
- 2026-10-02 11:45 UTC Greek Council of State tax rulings
- 2026-09-17 07:22 UTC Greek Council of State tax rulings
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